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For the advances here to be considered income receipts, the Court must be able to find that under and by virtue of his contract of employment the Appellant was entitled to commission based income and to advances on possible future earnings from time to time repayable solely out of that source which is to say that the future income if earned was to be the source and security for repayment with no liability to repay if it proved to be inadequate. ...

Factually, the evidence does not make it possible to determine that a portion of the expenses could be reasonably considered office expenses rather than lodging expenses. [2], [3]   Appellant’s alternate argument   [37]     The Appellant’s alternate position was that the expenses were deductible as travel expenses within the meaning of paragraph 8(1)(h) ...

Dawd, as he understood it, originally could have considered the construction of his own personal residence on the Dawd property from 1967 through 1972. ...

This decision of the Federal Court of Appeal was recently considered and approved in the decision of the Federal Court-Trial Division in Holiday Luggage Mfg. ...

Bains' 1994 tax return, said he considered that these funds were being "effectively paid back to Bhandar his advance to IPC". [18]     In 1990, Bains Co. claimed an allowable business investment loss of $97,410. ...

R. [1999] 2 C.T.C. 2127, Bowie J. considered the meaning of full-time attendance. ...

But, if the contract is held to be valid, a plea of mistake in equity may still have to be considered: see Grist v. ...

If we also look at the current subprime lending crisis, it clearly demonstrates the fragility of these investments, which are completely unsecured and can be considered as capital losses.   ...

Code correction is not considered to be a technological advancement. Rather, it is common practice in computer programming ...

It does not mean efforts to provide one's self with subsistence only, as the appellant contemplates, or an activity that creates some revenue, but not a profit, but at which the taxpayer devotes all of his mental and physical energies. [16]       Indeed, in Tonn [See Note 3 below] and Mastri [See Note 4 below] the Federal Court of Appeal considered the personal element of expenses in considering whether the expenses were incurred to produce income from a business or property. ...